Whistleblowing

WHISTLEBLOWING REPORTING

pursuant to Legislative Decree 24/2023, implementing Directive (EU) 2019/1937

In implementation of Directive (EU) 2019/1937, Legislative Decree no. 24 of 10 March 2023 (hereinafter “Decree”) was issued concerning “the protection of persons reporting breaches of Union law and containing provisions regarding the protection of persons reporting breaches of national legislation”.

The Decree repeals and amends the previous national legislation on whistleblowing, incorporating into a single legislative text the protection regime for individuals who report conduct—that is, behaviors, acts, or omissions—that constitute administrative, accounting, civil, or criminal offenses, committed in violation of national and European provisions and that harm the public interest or the integrity of the entity, provided the reports are based on concrete evidence.

They can forward the report to the Report Manager of CANDIDA SRL and of FIORE GROUP SRL :

• its employees, as well as self-employed workers and holders of a collaboration agreement who carry out their work activity at the Company;
• workers or collaborators of entities that supply goods or services or that carry out works for the Company;
• the freelancers and consultants who work for the Company;
• volunteers and interns, paid and unpaid, who carry out their work for the Company;
• those who do not yet work for the Company, but who may have acquired information during the selection or probationary phases, as well as former employees or collaborators, if the information was acquired during the employment relationship;
• people with administrative, management, control, supervisory or representative functions of the Company.

The identity of the whistleblower is known only to the Report Manager, who is obligated to protect its confidentiality, first and foremost, within the limits set by the Decree. The Company ensures the protection of the whistleblower in good faith against any retaliatory act, action, or behavior directly or indirectly related to the report. In the event of unfounded and/or bad faith reports, the Company reserves the right to take action to defend its interests and protect the injured parties. Specifically, reports made using the methods described above are exempt from the public access provided for by Article 5 of Legislative Decree No. 33/2013.

The Decree provides for various reporting methods:

• internal, i.e. addressed to the Company's Reporting Manager; external, i.e. addressed to ANAC;
• public disclosure, i.e. through the press or other means of dissemination.

It should be noted that the choice of reporting channel is not discretionary: whistleblowers are required to use the internal channel and, only when the conditions set out in the Decree are met, can they make an external report to the ANAC or make a public disclosure.

For further details, please read the document carefully before proceeding with the report. Procedure for Whistleblowing – pdf And Privacy Policy – ​​PDF

Internal reporting is the written or verbal communication of information about violations to the Company's Reporting Manager in whose workplace the whistleblower works. The Company has established the following channels for receiving internal reports:

• IT platform for text reporting https://whistleblowing-candida.digimog.it/
• voicemail https://whistleblowing-candida.digimog.it/
• direct and confidential meeting – by conveying the request through one of the aforementioned channels.

All channels guarantee the confidentiality of the identity of the whistleblower, the person involved, the facilitator, and any other person mentioned in the report, as well as the content of the report and related documentation. In any case, anyone submitting a report must specify that their identity is confidential and that they will benefit from the protections provided in the event of retaliation. Reports without the whistleblower's personal information will be followed up only if adequately detailed.

Finally, external reporting is the communication submitted to ANAC, in written or oral form, of information on violations that can only be activated when one of the following conditions occurs:

• the activation of the internal reporting channel has not been foreseen within the work context or this, even if activated, does not comply with the provisions of Article 4 of the Decree;
• the whistleblower has already made an internal report and it has not been followed up;
• the whistleblower has reasonable grounds to believe that, if he or she were to make an internal report, it would not be effectively followed up or that the report itself could give rise to the risk of retaliation;
• the reporting person has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest.

Information on how to make an external report is published on the ANAC website.